In August 2021, CMS (US Centers for Medicare & Medicaid Services) released new rules for the upcoming FY22 fiscal year. This update includes changes to the Hospital Inpatient Quality-Reporting (IQR) Program, which requires healthcare facilities to capture and report electronic clinical quality measures (eCQMs). 

The goal of this program¹ is to drive “quality improvement through measurement and transparency by publicly displaying data to help consumers make more informed decisions about their health care.” 

If they don’t report their data, hospitals can face financial penalties¹ that include not receiving the maximum payment amount to which they’re entitled.

What do hospitals need to know to prepare for this data collection and reporting measure?

Here are the questions you’ll find answers to on this page:

• What is the Hospital Inpatient Quality-Reporting (IQR) Program?
• When do these new IQR rules take effect and how long do hospitals have to get ready?
• What are the new glycemic management eCQMs announced in August 2021?
  • Severe Hypoglycemia
  • Severe Hyperglycemia
• How can hospitals improve their glycemic management programs in anticipation of reporting this data to the public? 
• How will hospitals know how their data will compare to other hospitals?
• How to take action and prepare

What is the Hospital Inpatient Quality-Reporting (IQR) Program?

According to CMS² (US Center for Medicare & Medicaid Services):

“The Hospital IQR Program is a pay-for-reporting quality program that reduces payment to hospitals that fail to meet program requirements. Hospitals that do not submit quality data or fail to meet all Hospital IQR Program requirements are subject to a one-fourth reduction in their annual payment update under the IPPS." 

In the FY 2022 IPPS/LTCH PPS final rule, CMS adopted 3 new eCQMs (electronic clinical quality metrics). These eCQMs will need to be collected starting January 1, 2023.

Reported metrics will be made available to the public via the Care Compare website.³

When do these new IQR rules take effect and how long do hospitals have to get ready?

The FY22 rules take effect October 1, 2021. 

Hospitals need to start collecting new eCQM data on January 1, 2023. Based on previous measures, we expect that the first year of data will be due at the end of February 2024. 

Hospitals have just over a year from the announcement to work with their EHR vendors to implement electronic data collection processes and reports. 

Given that two of these new eCQMs focus on glycemia, hospitals should use this time to:

• Take a closer look at their current glycemic management data
• Identify opportunities for enhanced patient safety and quality improvements
• Implement new technology and workflows that would enable optimal glycemic management best practices

What are the new glycemic management eCQMs announced in August 2021?

Among other changes announced August 2021, the FY 2022 IPPS/LTCH PPS rule finalizes the adoption of:²

“Two medication-related adverse event electronic clinical quality measures (eCQMs) (Hospital Harm-Severe Hypoglycemia eCQM (NQF #3503e) and Hospital Harm-Severe Hyperglycemia eCQM (NQF #3533e)) beginning with the CY 2023 reporting period/FY 2025 payment determination.”

To avoid payment penalties, hospitals must report on four of eleven eCQM metrics. 

Hospitals that intend on reporting eCQM metrics usually collect all necessary metrics and then determine internally which metrics they will publicly report. This means that even if hospitals choose to not publicly report these two new glycemic management eCQMs, there will be increased visibility and scrutiny from hospital leadership and quality departments on these specific metrics.

The two new glycemic management metrics are intended to measure the quality of the care provided by hospitals. Glytec’s team of clinical and regulatory experts reviewed CMS’s 2,295-page document⁴ collecting measure details, public comments and CMS’s responses and rationale to understand the nuance and intention of these new measures.

Severe Hypoglycemia Description (#3503e Hospital Harm Measure)

The Severe Hypoglycemia eCQM is intended to measure hospital-caused adverse drug effects.⁵

Severe hypoglycemia is defined⁵ as the proportion of inpatient admissions having one blood glucose recorded during their stay that is less than 40 mg/dL, collected within 24 hours of administration of insulin (or other antihyperglycemic agent). This applies to patients who are 18 years and older.

ACCORDING TO THE “DEVELOPER RATIONALE” PROVIDED BY CMS:

“Rates of inpatient hypoglycemic events are considered an indicator of the quality of care provided by a hospital…^6,7 Several important benefits related to quality improvement can be envisioned with the implementation of this eCQM." 

“Furthermore, this eCQM will encourage providers to implement interventions aimed at better glycemic control and prevent severe hypoglycemia for hospital inpatients." 

“In addition to avoiding direct patient harm from the severe hypoglycemic event, lower rates of hypoglycemia among hospitalized individuals would be expected to result in shorter lengths of stay and lower mortality.⁸”

Severe Hyperglycemia Description (#3533e Hospital Harm Measure)

The Severe Hyperglycemia eCQM9 is intended to measure prolonged hyperglycemia that is untreated by clinicians during a hospital stay, which could inhibit a patient’s ability to recover.

Severe hyperglycemia is defined as “the number of hospital days with a severe hyperglycemic event (a blood glucose result of >300 mg/dL or a day in which a blood glucose value was not documented and it was preceded by two consecutive days where at least one glucose value is >=200 mg/dL) per the total qualifying hospital days among inpatient encounters for patients 18 years and older who have either:

1. A diagnosis of diabetes mellitus,
2. Received at least one administration of insulin or an anti-diabetic medication during the hospital admission, or
3. Had an elevated blood glucose level (>200 mg/dL) during their hospital admission."⁹

According to the “Developer Rationale” provided by CMS:⁹ 

“Rates of inpatient severe hyperglycemic events – an extremely elevated blood glucose level – can be considered an indicator of quality of care provided by a hospital. Severe hyperglycemia is associated with a range of harms, including increased in-hospital mortality, infection rates, and hospital length of stay."^10-17

“The rate of severe hyperglycemic events varies across hospitals, which suggests that there are opportunities for improvement in glycemic management."^18-20

“The implementation of this eCQM will aim to achieve several improvements in quality. For instance, this eCQM will encourage providers to develop interventions aimed at better glycemic control and prevent severe hyperglycemia for hospital inpatients..."

“With a systematic EHR-based patient safety measure in place, hospitals can more reliably assess harm reduction efforts and modify their improvement efforts in near real-time. In addition, we can expect to make greater achievements in reducing harms and enhancing hospital performance on patient safety outcomes.”⁹

How can hospitals improve their glycemic management programs in anticipation of reporting this data to the public? 

These new CMS rules are significant because ineffective glycemic management isn’t a small problem. One third of all hospitalized patients require insulin therapy during their stay.¹² This includes the 34 million Americans living with diabetes and 84 million with prediabetes.²¹ 

On top of patients with known or pre-existing glycemic management challenges, there are many other reasons for patients to require insulin in the hospital. For example:

• Stress hyperglycemia can occur when a person’s body is under duress and oftentimes occurs after surgery.¹²
• Steroids – like dexamethasone, one of the most common treatments for COVID-19 – can raise blood sugar levels because they cause insulin resistance.²²
  
  

These new measures finally answer the calls the American Diabetes Association²³ has been making for two decades for hospitals to make the changes necessary to achieve the standard of care for inpatient glycemic management. 

These measures will create the incentive for hospitals to prioritize glycemic management, which can be difficult without the proper support and technology. There are challenges to achieving optimal glycemic management, but it’s a must-have given that it benefits patients’ safety and helps reduce costs for individuals, hospitals and the public.

Insulin dosing in the inpatient setting has remained largely unchanged for half a century. Simplified protocols seek to ease provider burden but can’t provide personalized care. Meanwhile, more complex protocols that are dependent on manual calculations are prone to dangerous errors.²⁴

Reliance on protocols that don’t dynamically adjust based on patient needs is strongly discouraged by the American Diabetes Association.²³ 

Glytec’s patented, FDA-cleared insulin dosing algorithm and decision support module Glucommander, the core of Glytec’s eGlycemic Management System (eGMS), has been shown in multiple peer-reviewed clinical studies to help hospitals reduce inpatient hyperglycemia and hypoglycemia.²⁵ 

Our technology is designed to help clinicians personalize insulin dosing while reducing clinical variation by guiding providers and nurses to best practice care. Glytec’s eGMS is designed with engineered safety guardrails and integrations to provide a seamless user experience that leverages all available clinically-relevant patient data.

Our team of clinical experts provide insights that help develop technology that solves our partners’ needs, and also advise our customers on change management and optimal processes. We know that technology is just one piece of glycemic change management, which is why we provide white-glove implementation, robust training resources, post-implementation quality improvement support as well as 24/7/365 technical support.

Learn more about Glytec’s solutions or schedule a demo to learn how Glytec can help you prepare for the CMS measure.

How will hospitals know how their data will compare to other hospitals?

Hospitals will also be accountable to the public, who will be able to view this data on a website and compare how hospitals manage patient safety. The reported data from 2023 likely won’t be available until October 2024. 

Even before any data needs to be reported to CMS, hospital leadership will be reviewing their glycemic management data internally to decide which eCQMs to report, creating greater scrutiny on glycemic management as a core metric of patient safety. 

CMS is making it clear that severe hypoglycemia related to insulin should be a never event and that hospitals should work towards that goal, and as such hospitals need to prioritize the optimal treatment and management of severe hyperglycemia. 

Many hospitals think their rates of severe hypoglycemia and severe hyperglycemia are generally acceptable; however, several of our newest partners have indicated that they didn’t realize how big of an issue they had with hypoglycemia/hyperglycemia until they saw the positive impact of implementing Glytec’s eGMS.

The truth is, these glycemic management eCQMs are a priority for CMS because they know that most hospitals could do better. While benchmarks for the CMS metrics will not be available until October 2024, hospitals should prepare for the measure by evaluating their current glycemic management solution and identifying areas for improvement.

How to Take Action And Prepare

Glytec is Here to Help

We’ve developed glycemic management technology and a proven change management process that is designed to optimize patient safety and meet our partners’ needs. We can help you get started quickly and guide you and your team through the configuration process. 

We know that change management isn’t just about having the right tools: you also need the right people and process. 

Our FDA-cleared eGlycemic Management System is backed by multiple peer-reviewed studies showing its efficacy in helping reduce hyperglycemia and hypoglycemia.²⁵ We ensure that our partners get the full value of our software by providing the clinical and technical expertise to guide our partners in creating and managing best-in-class glycemic management programs starting with our initial implementation and ongoing throughout our relationship.

If you’re not a current Glytec partner, we’d be happy to discuss how we can help you prepare for the CMS measure and support your team throughout these changes.